SECTION 8. WHAT ARE THE

GENERAL INSTRUCTIONS FOR REQUESTING LETTER RULINGS AND DETERMINATION LETTERS?

.11 Generally not to business associations or groups

.12 Generally not to foreign governments

.13 Generally not on federal tax consequences of proposed legislation

.14 Issuance of a letter ruling before the adoption of regulations

p. 19 .01 In income and gift tax matters

.02 In estate tax matters

.03 In generation-skipping transfer tax matters

.04 In employment and excise tax matters

.05 Circumstances under which determination letters are not issued by

district director

.06 Requests concerning income, estate, or gift tax returns

.07 Attach a copy of determination letter to taxpayer’s return

.08 Review of determination letters

p. 21 .01 Ordinarily not in certain areas because of factual nature of the problem

.02 Not on alternative plans or hypothetical situations

.03 Ordinarily not on part of an integrated transaction

.04 On constructive sales price under § 4216(b) or § 4218(c)

p. 21 .01 Certain information required in all requests

(1) Complete statement of facts and other information

(2) Copies of all contracts, wills, deeds, agreements, instruments, and

other documents

(3) Analysis of material facts

(4) Statement regarding whether same issue is in an earlier return

(5) Statement regarding whether same or similar issue was previously

ruled on or requested, or is currently pending

(6) Statement of supporting authorities

(7) Statement of contrary authorities

(8) Statement identifying pending legislation

(9) Statement identifying information to be deleted from copy of letter

ruling or determination letter for public inspection

(10) Signature by taxpayer or authorized representative

(11) Authorized representatives

(12) Power of attorney and declaration of representative

(13) Penalties of perjury statement

(14) Number of copies of request to be submitted

(15) Sample format for a letter ruling request

(16) Checklist for letter ruling requests

.02 Additional information required in certain circumstances

(1) To request separate letter rulings for multiple issues in a single

situation

(2) To designate recipient of original or copy of letter ruling or

determination letter

(3) To request a particular conclusion on a proposed transaction

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